many environmental benefits or experience as much wildfire. Whereas profitable woody bioenergy markets would encourage nonindustrial private owners to adopt more formal and frequent silvicultural treatments,67that incentive is reduced or altogether eliminated without a biomass buyer. These foregone environmental improvements are a cost of excluding public and naturally regenerating forests from the biomass market. Not surprisingly, there is widespread support among state foresters and state biomass contacts for expanding the renewable biomass definition to include biomass from naturally regenerated forest stands.68

Third, excluding naturally regenerating forests from the biomass market closes off a potential revenue stream for nonindustrial private forest owners. Many nonindustrial private forests have large quantities of small diameter trees and logging residues marketable for bioenergy production.69As the Society of American Foresters notes, “this additional revenue stream from renewable biomass for forest landowners can help them keep their forests forested, rather than selling them for development.”70 Moreover, revenue streams from complimentary forest products, like woody biomass, provide opportunities for landowners to “reap more value from their forests while simultaneously enhancing wildlife habitat, water quality, and even scenic beauty.”71

Mandating the use of renewable fuels contradicts free market principles and will undoubtedly raise fuel costs. Combining such a mandate with an arbitrary exclusion of renewable fuels grown on nonindustrial private forests creates a subsidy for industrial forest owners. Without the opportunity to compete on a level playing field with industrial forests, nonindustrial private forest owners are unlikely to invest in renewable biomass production. As one forestry advocate predicts, “the definition’s arbitrary limits on qualifying private forest lands can only exacerbate the land-use conversion pressures faced by our smaller, private working forest landowner.”72